Last updated: January 25, 2019
When reviewing this Policy, the following terminology may be helpful:
Please read this Policy carefully. By accessing and/or using the Site, you acknowledge that you have read, understood, and agree to the practices and procedures in this Policy. If you do not agree, your choice is not to use the Site.
For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”), the Data Controller is Milo Credit, LLC, registered in Delaware with a registered address at 78 SW 7th St, Suite 500, Miami, FL 33130.
Our nominated representative for the purposes of the GDPR is [Josip Rupena].
Our Data Protection Officer is Josip Rupena who can be contacted by sending an email to firstname.lastname@example.org or by post to 78 SW 7th St, Suite 500, Miami, FL 33130.
If you have any questions about this Policy, please feel free to contact us at by email at email@example.com, by phone at 888-433-6456, or by post at 78 SW 7th St, Suite 500, Miami, FL 33130.
Information that you give us voluntarily
We may collect and process the following information that you give us voluntarily (and which may include Personal Data and Special Category Data):
Information collected from you automatically
We and our third party service providers may use automatic data collection technologies to collect information from you as you use the Site, including information about your online activities over time and across third party websites or other online services.
Types of information collected automatically
Any time you access and/or use the Site we will automatically collect the following information:
For information about the choices you may have about data collected using automatic data collection technologies, please see the section on Your Information Collection Choices below.
Types of automatic data collection technologies we use
The Site currently uses the following automatic data collection technologies to collect information from you automatically:
We may use our own cookies to collect information as well as cookies provided by certain advertising and web analytics third party service providers, such as Google AdWords; and/or Google Analytics. For more information about how Google uses this data, please visit https://policies.google.com/technologies/partner-sites.
Information we receive from other sources
We may also collect information about you from third parties, including:
We will only process your Personal Data, including sharing it with third parties, where: (1) you have provided your consent which can be withdrawn at any time; (2) the processing is necessary for the performance of a contract to which you are a party; (3) we are required by law; (4) it is required to protect your vital interests or those of another person; or (5) it is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.
We will only process Special Category Data on the legal basis of: (1) your explicit consent; (2) employment or social security and social protection law requirements; (3) protecting your vital interests or those of another person; (4) the establishment, exercise, or defense of legal claims; (5) reasons of substantial public interest; (6) medical and healthcare purposes; or (7) where you have made such data public.
We may use Personal Data for the following purposes:
Personal Data you give to us voluntarily
Personal Data collected from you automatically
Personal Data we receive from other sources
We may also process your Personal Data as required by law or based on our good faith belief that it is necessary to conform or comply with the law or to protect the users of the Site, the Site, or the general public.
We may use your information to contact you in the future to tell you about products or services we believe may be of interest to you. If we do, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us using the How to Contact Us section above.
We use web beacons to tell when a user is redirected to the Site because of an advertisement that we ran was clicked on or otherwise interacted with and to better target our advertisements (known as “retargeting”). Our service providers may track Site visitors across multiple websites and social media services to retarget Site visitors. Users logged in to social media programs may be tracked by service providers who track such users across multiple websites and who may disregard the privacy settings in your web browsers.
We may share information that is not your Personal Data without restriction, including aggregate information about visitors to the Site and information that does not identify any individual.
We may share your Personal Data for the purposes described in this Policy:
We will not transfer Personal Data, relating to individuals within the European Economic Area (“EEA”), to third parties located outside of the EEA without ensuring adequate protection under European law. Where a third party is located in a country not recognised by the EU Commission as ensuring an adequate level of protection, we will take appropriate steps, such as implementing standard contractual clauses recognised by the EU Commission, to safeguard your Personal Data.
You can limit some of the tracking mechanisms that automatically collect information about your use of the Site, such as by setting your browser to opt out of cookies.
You can refuse to accept cookies by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being set. You will need to manage your cookie settings for each device and browser you use. However, if you do not accept cookies, you may experience some inconvenience in your use of the Site and some online products and services. For example, some parts of the Site maybe inaccessible or not function properly. You also may not receive tailored advertising or other offers from us that may be relevant to your interests and needs. For more information about cookies and how to manage or delete them, please visit http://www.allaboutcookies.org/.
California Do Not Track disclosure
Our Site currently does not respond to “Do Not Track” signals. For a description of “Do Not Track” information for browsers and mobile devices, and information about opt out programs that third party advertising companies participate in, please visit https://allaboutdnt.com/.
You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Data. You can also exercise the right by contacting us using the How to Contact Us section above.
Under European data protection law, in certain circumstances, you have the right to:
In addition, where you believe that Milo Credit has not complied with its obligations under this Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.
You can exercise any of these rights by contacting us using the How to Contact Us section above.
We will store your Personal Data, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the Personal Data is processed. We may retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it.
Consistent with these requirements, we will try to delete your Personal Data quickly upon request.
Data Storage and Security
We store all your Personal Data on our secure servers.
We use appropriate measures, including advanced technology, to protect Personal Data collected online from unauthorized access or disclosure. These measures may include transmission through Secure Socket Layer technology, encryption, physical access security, and other appropriate technologies. We review and enhance our security measures as necessary. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Links to third party websites
We may create links to third party websites, including in the form of widgets (e.g., social share buttons) that enable users to easily share information on another platform, such as a social media platform. The third parties that own these widgets may have access to information about your browsing on the Site where these widgets are placed.
We do not evaluate and are not responsible for the privacy practices or content of third party websites, including the websites of our affiliates. We encourage you to review the privacy policies of each link to ensure that you are comfortable with their privacy practices.
Privacy of children
The Site is not directed at persons under the age of 18, and Milo Credit does not knowingly collect or maintain information provided online by persons under the age of 18.
We may make changes to this Policy from time to time. Should we make a material change to our information collection and processing practices, we will let you know by updating this Policy and revising the “Last Updated” date. Such changes will be applied only to information collected on a going forward basis. Your continued use of the Site following the posting of any changes to this Policy indicates your acceptance of the new terms.